|
10th
July 2009 Caroline
Cody Commission
on Taxation Ship
Street Great, Dublin
8, REF:
Carbon Tax |
Dear
Caroline,
I
refer to the above and the following are my thoughts and suggestions to improve
Tax revenue whilst at the same time improve the environment, and incentivise job
creation and investment. The suggestions follow from my experience in my
own business:
1.
Cross
border trade in solid fossil fuels (Coal, etc.) is growing. In many cases no VAT
is charged to Southern customers and is not paid on retail sales to the Irish
Government. Revenue need to confront sources, both north and south
simultaneously at the early stage in a co-ordinated way. It seems that Revenue
are reluctant to do so, if returns are not big enough in financial terms. This
is grossly unfair to legitimate businesses who pay their
taxes.
2.
All
fuel merchants should be licensed – I cannot legally employ a haulier to
transport a load of coal unless I have his licence in my possession, while the
value of the load of goods can be twenty five times higher than the transport
cost with no licence required.
3.
Chopped
Wood: Up to a million tonnes is sold in the Irish Republic market at a
value of circa €225 million. At best VAT is paid on 10% of this € 225
million.
4.
Sod
turf: Circa 600,000 tonnes are sold in the Republic market. Revenue circa € 150
million. VAT might be paid on 75 % of this. PLEASE IN YOUR THINKING
PROCESS.........
5.
Why
is the Government as the largest importer of bituminous products thought it’s
ownership of Bord Na Mona importing these products at the same time, talking of
imposing Carbon Taxes? It’s a contradiction isn’t
it?
6.
Should
the Government not repeal the legislation that was specifically constructed to
protect processed peat and classify it as a smokeless fuel, which it technically
clearly is not. In fact it emits about 15% more CO2 than bituminous coal. In
fact given the figure above on sales of 600,000 tonnes sold, and CO2 emissions
from sod turf is 4mt per mt of turf, this would suggest approximately 2.4m
tonnes of CO2 from sod turf. Also, peat is not classified as a smokeless fuel in
the North of Ireland.
7.
In
the context of the points I’ve made in items 4 – 6, the Government on the one
had is promoting a Green Economy (which I applaud) and is asking individuals and
companies to invest in schemes such as forestry planting as a source of home
produced fuels going forward. The question is why should they invest when there
is a huge unregulated market competing against them, who pay little or no taxes
to the state, either VAT, Corporation Tax, PAYE or PRSI.
A
regulated trade can help to collect taxes, can help the state to identify the
fuels sold in the state and therefore have much more confidence about how much
CO2 is produced within the state.
I
have certain expertise which I am happy to discuss with you, which can assist in
helping to achieve the above and it’s my view that waste and protectionism as
outlined above, should be address prior to imposing a Carbon
Tax.
The
Solid Fuel Trade Group of which I am a member, and has a written voluntary
agreement with the Department of the Environment in connection with the import
of all solid fossil fuels into the state, could greatly help you in this area
and I would be happy to facilitate such a situation.
Yours
sincerely,
Pat
O’Sullivan
Managing
Director
Galtee
Fuels Ltd
Barrigone
Askeaton
Co
Limerick
Tel:
069 – 65200
Email:
info@galteefuels.ie